So Cotton, you are saying that the new definition for non-CDA Claims was introduced/changed in the Settlement from the previous language in the Settlement as below to make it clear that the cTs are covered by the Lehman Guarantees provided in "September 2008 Guarantees & Security Agreements" to JPMC about the CTs, as below??
New language in JPMC/LBHI Settlement, as of 1/25/2017:
"and any other filed claims that JPMorgan did not assert were covered by LBHI’s August and September 2008 guaranties and security agreements."
VS OLD Language:
"otherwise in respect of which JPMorgan did not assert in the relevant proofs of claim that such claims were secured by the collateral posted by LBHI pursuant to the parent level guaranties at issue in the Avoidance Action."
I guess this means the NEW Language in the Settlement Agreement is Clearly stating that the that NON-CDA Claims (CTs etc) are covered by the Guarantees in the Prospectuses ("are covered by LBHI's August and September 1008 guarantees and security agreements") and those Guarantees are "to be Enforced", as part of this Settlement.